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A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part II

The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and...more

A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part I

The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and...more

Now Including the Kitchen Sink: Expansion of Export Controls on Russia Adds Restrictions on Low-Level Items and Software

Last year, we published an update on BIS’s foray into prohibiting EAR99 items for export to Russia and Belarus. We noted (somewhat in jest) that kitchen sinks may one day be added. Well, that day has come. Stainless steel...more

China Semiconductor Export Regulations, Episode III – What a Difference a Year Makes

On Tuesday, October 17, 2023, the U.S. Bureau of Industry and Security (BIS) released a package of three rules (the 2023 Rules) targeting the Chinese semiconductor industry. The rules update the substantial semiconductor...more

Don’t Let the Government Name, Shame, and Fine You – Export Controls Do NOT Excuse Hiring Discrimination

When can an employer use the “national security exception” under U.S. anti-discrimination law to make a hiring decision based on the national origin of the candidate? An often overlooked area of compliance is how to comply...more

The New Containment: How the Semiconductor Industry Came to be at the Heart of the Technological Cold War

As you may have heard here (and here and here), in October 2022, the United States issued sweeping measures aimed at the semiconductor industry in China. The new regulations restrict the export of semiconductors and related...more

China Semiconductor Export Regulations, Episode I – Counting Your Chips Carefully

The Announcement On Friday, October 7, 2022, the U.S. Bureau of Industry and Security (BIS) released for public inspection (available ...) one hundred forty pages of regulations (which we’ll call “the Regulation” here) that...more

U.S. Government Pursues More Aggressive Action to Curb Espionage at Universities

The U.S. Governmental Accountability Office (GAO) thinks the FBI and other agencies are not doing enough to address the espionage threat on U.S. university campuses. It issued a report, “Enforcement Agencies Should Better...more

Huawei Whack-A-Mole: The U.S. Takes Another Swing at the Chinese Semiconductor Industry

On Tuesday, May 19, the U.S. Commerce Department published a regulation (effective May 15, 2020) that prohibits sale to Huawei of a microchip made to a Huawei specification, made outside the United States with non-U.S....more

Hua-Wait a Minute: Entity Designation Affects Non-U.S. Manufacturers’ Exports to China Tech Giant

On May 16, 2019, a sweeping U.S. export control rule went into effect that will impact the U.S. tech industry, but may also create an outsized risk for non-U.S. manufacturers. The rule, issued by the U.S. Department of...more

Another Day Another Tariff… and Other Recent Restrictions on China

In what has become his trademark Trumpian manner, the President announced last Friday that new tariffs and trade restrictions against China are on again, at the same moment that his senior Commerce and Treasury Department...more

America Turns A Page: Cuba Removed From U.S. List of State Sponsors of Terrorism

The United States officially removed Cuba from its list of State Sponsors of Terrorism today, according to an announcement by the U.S. State Department via Twitter. The change takes effect immediately, according to the...more

Streamlining the System: More Baby Steps Toward Reducing Export Compliance Burdens

Since 2011, President Barack Obama’s administration has actively pursued export control reform designed to reduce the regulatory burdens on U.S. companies and enhance U.S. national security (as reported here). On March 7,...more

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